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On November 4, 2009, Mr. Cacapit attempted to contact Mr. Johnson by phone <br /> regarding the 48-hour notification for the August 14, 2009 secondary containment <br /> testing. There was no answer. <br /> On November 5, 2009, Mr. Cacapit sent another follow up fax to Mr. Khajevandi asking <br /> for a return to compliance certification and corrective actions statement for the <br /> November 17, 2008, hazardous waste inspection report (Attachment 28). <br /> On November 6, 2009, Mr. Cacapit spoke to Mr. Johnson and asked about the 48-hour <br /> notification. Mr. Johnson stated that he remembered that he was supposed to send <br /> documentation that he provided notification for the testing, and that he would send it that <br /> day. <br /> On November 17, 2009, Mr. Cacapit sent a letter to the facility informing Mr. Khajevandi <br /> and Ms. Haleh Amiri, Partner, that the EHD has rejected the August 14, 2009, secondary <br /> containment test results and that testing would have to be immediately scheduled, 48- <br /> hour notification provided to the EHD, and completed (Attachment 29). <br /> On December 3, 2009, notification for secondary containment testing on December 7, <br /> 2009, was submitted (Attachment 30). <br /> On December 4, 2009, lab analysis for soil cuttings, disposal receipt for two drums of <br /> soil cuttings, and a disposal receipt for a container of used oil filters was submitted <br /> (Attachment 31). A corrective actions statement for the November 8, 2008, hazardous <br /> waste inspection and disposal receipts for two containers found on site during the July <br /> 30, 2008, but not during the November 8, 2008, inspection were still lacking. <br /> On December 29, 2009, a secondary containment test report was submitted for testing <br /> performed on December 7, 2009 (Attachment 32). <br /> On July 26, 2010, Mr. Jeffrey Wong, Senior REHS, EHD, performed a routine hazardous <br /> waste inspection (Attachment 33). A monitoring system certification was also scheduled <br /> for the day, but the testing company called to reschedule after Mr. Wong had arrived on <br /> site. During the inspection, Mr. Wong found a 55-gallon container labeled "Drained <br /> Used Oil and Gasoline Filters" that contained three filters, a used dispenser nozzle and <br /> hose, and approximately 15-20 gallons of oily liquid. Eight universal waste fluorescent <br /> bulbs were not stored in a closed container and it could not be determined how long the <br /> lamps had been stored. Photos are attached (Attachment 34). <br /> On July 28, 2010, Mr. Cacapit performed a routine UST inspection and witnessed the <br /> monitoring system certification, leak detector testing, and spill container testing. The 91- <br /> octane fill sump sensor failed when tested (and was replaced on site), leaks were found <br /> in dispensers 5/6 and 9/10, and approximately one quart of liquid was found in the 91- <br /> octane piping sump and approximately '/2 gallon of liquid was found in the diesel piping <br /> sump. During a review of the facility's paperwork, Mr. Cacapit found that secondary <br /> containment was last performed five months late and financial responsibility documents <br /> were submitted one month late. The UST operating permit and maintenance records for <br /> nine alarms were not found on site. In the designated operator monthly inspection <br /> reports, two alarms were not documented in the monthly inspection reports and <br /> secondary containment test dates were incorrectly noted. Mr. Khajevandi was working <br /> alone and he did not have current training by the designated operator. Mr. Cacapit did <br /> 4 <br />